Safety at sea

As a shipowner you have the opportunity to invest in battery operated ships. The Danish Maritime Authority has drawn up guidelines on large battery installations on board ships. The guidelines have been developed on the basis of the experience gained from the conversion of a number of passenger ships for hybrid operation, where one or more auxiliary engines are replaced by a battery installation of up to 2.4-3 MWh. The recognized classification societies' regulations on electrical installations can, in principle, also be used for battery installations, but there are problems with a number of safety-related requirements since several modern batteries have the disadvantage that, in case of a defect, a fire may arise that cannot be extinguished right away due to the chemical reactions. Here, the regulations on alternative design and documentation for the installations by means of a risk analysis are used.

The following provides an overview of the issues to be considered in connection with applications for bunkering and the establishment of LNG bunkering installations in Denmark. When you apply for bunkering or for the establishment of bunkering systems, you should be aware of several issues.

They concern: Safety, the environment, security, occupational health and construction works – and are of relevance to the applicants as well as to the authorities. For local, geographical or constructional differences, it is not possible to draw up guidelines as such on bunkering and the establishment of LNG bunkering installations. Therefore, the contents on this page should be considered an overview of current regulations, relevant authorities, etc.

It should be stressed that there may be local conditions that necessitate further consideration that have not been included in this overview. Therefore, the overview serves only as guidance, and it is recommended to engage in dialogue with the relevant authorities early in the process.

Relevant authorities

In connection with the consideration of an application for bunkering LNG in Denmark, the applicant must usually contact two authorities:

• The Danish Maritime Authority, which takes care of the part related to the ship, including bunkering from another ship.

• The municipality, which takes care of the part related to bunkering and the shore-based facilities, including any cooperation with other authorities.

Bunker operations and the establishment of LNG bunkering installations may influence, for example, the municipal environmental or business policy, which may necessitate political consideration of the case. Such consideration will affect the case consideration, the procedure applied and the period of time spent considering the case.

The municipality and the Danish Maritime Authority must coordinate, inter alia to create homogeneity and coherence, for example in connection with bunkering, shielding and shore-based possibilities of evacuation. Finally, other authorities may need to be consulted and/or to grant a bunkering permit. Other authorities may be the Danish Emergency Management Agency (safety and preparedness), the Danish Working Environment Authority (safety at work) and the police (terrorism threat assessments and counter-terrorism security).

Process and coordination

In order to make things easier for the applicants, the Danish Maritime Authority and the municipality are striving to ensure that the applicant can use them as an entry point for other authorities. The municipality has many areas that must be included, while the Danish Maritime Authority may be the first authority that is in contact with the shipowner when the process approving the ship is initiated. Already at the start of the case (before applications, etc. are drawn up), it may be a good idea to have a meeting with all the parties concerned, such as the shipowner/shipyard, gas supplier, port, municipality (inter alia environmental and emergency preparedness personnel) and the Danish Maritime Authority. If it is not possible to gather all the parties, a meeting should at least be held between the municipality and the Danish Maritime Authority. At such a meeting, the future process, the sequence of the case consideration, coordination and interfaces between the authorities, etc. could be agreed. It may be a good idea to discuss the requirements for, inter alia, risk assessments and evacuation plans to ensure that overlapping analyses are not drawn up. In addition, it may be a good idea to discuss already at the start what the specific application should contain. In this manner, the necessary basis for a final approval can be created early in the process.

The application

Changes may arise in the course of the case consideration. Therefore, it is decisive that the changes are documented and described in such a manner that the basis for a permit is unequivocal.

The material contained in the application may cover several authorities. Therefore, it is recommended that the requirements for the contents, drafting and approval be coordinated in connection with the following areas:

• Risk analysis

• Passenger accommodation and movements during bunker operations

• Evacuation plan

• Communication equipment for on-board and shore-based operators

STS (ship-to-ship) operations refer to the transfer of cargo from the cargo hold of one tanker to that of another. The operation is mandated by a number of special safety procedures. In Danish waters, most STS operations take place in Aalbæk Bay at Frederikshavn in Northern Jutland or on Danish EEZ. In the tables below, you can find more information about the number of STS operations, where they are carried out and how much oil is transferred.

STS operations in Danish and Greenland territorial waters

The provisions of the order on STS operations cover tankers carrying out STS operations in Danish and Greenland territorial waters.

According to the regulations, STS operations must be carried out under the guidance and supervision of an approved STS operator and in accordance with the most recent international industry recommendations. The Danish Maritime Authority approves STS operators upon application. STS operators must pay the costs related to the approval. Approved STS operators must use a quality management system that ensures that their tasks are carried out in accordance with the provisions of the order.

The Defense Command, Naval Staff, as well as the Arctic Command must be informed about the transfer and tankers carrying out cargo transfers in Danish territorial waters are covered by the obligation to take a pilot in accordance with the pilotage act.

STS operations outside Danish territorial waters

Regarding STS operations outside territorial waters, the provisions of United Nations' International Maritime Organization (IMO) apply. The regulations stipulate that the operation must be carried out in accordance with an approved plan, which is made on the basis of the ship's construction, equipment and valid industry guidelines for "best practice" in the area. In addition, the operation must be reported to the relevant authorities in the coastal State.

Furthermore, HELCOM (Baltic Marine Environment Protection Commission - Helsinki Commission) has developed a set of recommendations for guidelines on bunkering operations and ship to ship cargo transfer of oils in the Baltic Sea Area. HELCOM is the governing body of the Convention on the Protection of the Marine Environment of the Baltic Sea Area.

In 2018, 62 STS operations were performed outside Danish territorial waters but inside the Danish EEZ. The quantity transferred however was only 151.627 tonnes of which only three operations involved the transfer of more than 5.000 tonnes. In all cases the transfer dealt with bunker oils, being transferred to small tankers approved to perform bunkering operations in Danish territorial waters. Bunker ships which subsequently distributed the bunker oils to other cargo ships for their daily power consumption.

Inspections

The Danish Maritime Authority carries out inspections of operations in Danish and Greenland waters on the basis of random checks.